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McDONALD v. COMMISSIONER

Docket No. 429-67.

52 T.C. 82 (1969)

ARTHUR D. McDONALD AND JESSIE L. McDONALD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 16, 1969.

Attorney(s) appearing for the Case

H. Milton Innerfield, for the petitioners.

Ferdinand J. Lotz III, for the respondent.

SIMPSON, Judge:

The respondent determined a deficiency of $26,545.90 in the petitioners' income tax for the taxable year ending December 31, 1961. There are two issues for decision: (1) Whether a redemption of stock by a corporation pursuant to a plan for the acquisition of such corporation is essentially equivalent to a distribution of a dividend; and (2) whether, on the facts presented, a legal fee is deductible under...

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